Comment to NEPA Project Number DOI-BLM-ORWA-0000-2026-0001-RMP-EIS

Comment to NEPA Project Number DOI-BLM-ORWA-0000-2026-0001-RMP-EIS

Fellow Citizens:

I write as someone whose career, like yours, was in public service as a government employee (administrative law judge). I know you know that you are required to read every comment you receive and give it due consideration before taking further action on this matter.

In retirement, I have educated myself more as a naturalist in an effort to provide even more public service to Life. When I travel to Oregon about four times each year, I love to recreate in the forests. I enjoy hiking the mossy trails and identifying the flora and fauna, especially the wild mushrooms. Being in the woods restores my spirit and my hopes for the future. One of those hopes is that we humans learn from the lives and experiences we have been given. You seek a return to the logging frenzy of the 1960’s, when the carbon dioxide level in the atmosphere was in the low 300’s. Forests were still able to do their jobs of sequestering carbon back then. Now – if you haven’t been paying attention – we are past the first quarter of the 2000’s and the carbon dioxide levels are soaring past the danger zone, above 410. We need more trees and more biodiversity, not less! 

In this part of my life when I have leisure to recreate, it grieves me to drive past the havoc in destroyed forests. I see clearcut fields where stately trees once stood as guardians of our children’s future. As a personal decision, the travel dollars I have spent to recreate in wild places may soon be diverted from Oregon to another, more consciously managed location. 

Please do not destroy more forests by so-called “thinning” to support the logging industry’s inefficient and retrograde practices. Please use the tools of good governance to encourage them to update and redirect their workforce to future-oriented service!  Please devote yourselves to care for what we have been given, and restore what has been lost! 

Please slow down and review the best available data on the priorities you set: bolstering local economies related to the forests; and protecting people and property from forest fires. The path you are considering is counter-productive for both priorities!

Please consider the best available science now emerging as communities across the country learn from recent fires: 

A healthy living forest ecosystem with a biodiverse understory does the following to prevent and slow fire: 

  • Maintains hydration by circulating water from the ground through the living trees and other plants, up into the atmosphere, 
  • Causes rain by seeding rain clouds with diverse microorganisms that enter the atmosphere through transpiration, 
  • Cools the local region by 5-10 degrees,
  • Keeps trees wet inside, preventing them from burning rapidly. Trees in healthy living forest ecosystems are wet inside and do not burn rapidly. 
  • Turns atmospheric carbon dioxide into the oxygen that humans and animals need, 
  • Fosters a damp and spongy soil structure which absorbs moisture, cleansing and ultimately adding to streams and rivers,
  • Recycles dead wood and leaf litter in a way that sustains beneficial insects and wildlife, recycles nutrients, and supports soil moisture,
  • Serves as a windbreak from dry hot winds,
  • Reduces flood/drought cycles, 
  • Prevents soil degradation and erosion, and
  • Resists infestations of harmful elements, like insect pests. 

Thin-and-burn strategies ultimately undermine the above capacities of a forest. Moreover, they fail  to prevent loss of life and property. In some documented cases, that strategy made the damage much worse. When the moist forest ecosystem is disrupted by thinning, dry wind tunnels occur that accelerate the fire instead of slowing it down. As one example, the 2018 Camp Fire in California devastated homes, despite thin-and-burn strategies upwind of Paradise that the residents expected to save them. Most – up to 90 percent – of fire damage is caused by wind.

  • The best available science prioritizes fire-hardening structures and everything within a hundred-foot radius of those structures, combined with enhanced monitoring of visitors to forests to avoid campfires, and getting humans out of harm’s way fast in an emergency. While very costly to individuals, fire-hardening should be publicly funded by all levels of government because it is the best way to avoid widespread loss of human life and property. Building with steel instead of wood makes sense, as every child knows from hearing about the Three Little Pigs, and as grown-up architects like Carl Welty and Katheryn Alexander know.
  • The best available science promotes a general long term strategy of rehydrating the landscape, by (a) maintaining healthy living forest ecosystems to provide the ecosystem services described above; (b) rehydrating non-forested rural areas such as farms and ranches; and (c) rehydrating more populated areas, including urban ones.  
  • The kind of jobs that fit our current challenges are not destructive ones like clear-cut logging. We need workers in the field who can restore the capacity of clear-cut fields to function again in their God-given purpose as biodiverse living forests, providing future generations as yet unborn the same chance to live a long full life that we current humans received from Nature. 
  • Construction jobs need to focus on steel construction rather than wood, and we need to be more efficient with the wood products that continue to make sense to harvest. First, they should stay within the United States. Second, they should not be used structurally in homes at risk of wildfire.

Some Resources:

Fostering Socio-Ecological Resistance to Wildfire by Interconnecting Knowledge Systems at Cal Poly Humboldt, by Jeffrey M. Kane, Erin Kelly, Benjamin Graham, and David Greene (“forest desertification that resulted from past state and federal land management policies”). Home hardening discussed at p.13 of 25.

The Rabbit-Duck Illusion in Climate Messaging: An Example from Wildfire Policy, by Anastassia Makareiva.

Smokescreen: Debunking Wildfire Myths To Save Our Forests, by Chad Hanson, PhD.

Unseen Connections Between Life and Climate, by Hart Hagan.

How Plants Cool the Planet, short video by Jimi Sol.

How Trees Bring Water, short video by Andrew Millison.

How Plants Water Our Planet, academic article by Douglas Shell.

 In the article “The Orchard at the End of Paradise” (Van der Leun, 2018), land owners describe the phenomenon of their apple orchard remaining unburned while the Camp Fire moved around it. June 2020 Literature Review for Paradise Nature-Based Fire Resilience Project (“Literature Review”) page 9 of 25, which also states, “an increase in bulk density and fuel moisture content results in an increase in the time to ignition”.

Insect Life Under the Leaves, by Heather Desourcie is an example of how leaf litter that may look like it’s flammable is actually supporting the biodiverse ecology that keeps the forest alive.

Will Pattiz on what is ultimately at stake, including this passage from his More Than Just Parks substack today: These forests are not a resource. They are a place. They are a place in the way that a cathedral is a place, in the way that the ground where your family is buried is a place. You do not walk into a grove of thousand-year-old Douglas fir and think about board feet. You think about time. You think about what it means that something this large and this patient has been standing here since before your civilization learned to write its laws down. You think about what kind of people we are if we let it fall.

Sincerely,

[Concerned]